CONFESSIONS OF A
MONEY LAUNDERER by Kenneth Rijock
Financial Crime Consultant, for World-Check
Confessions of a Money Launderer - Part 86
22 February 2009

So how did I become a compliance officer in an investment firm that was later revealed to be a covert billion-dollar Ponzi scheme? And what happened after it was exposed by regulators? Let us start at the beginning. As a compliance consultant, I was often called upon to step in with little or no prior notice. One afternoon, a prominent Miami banking attorney who is a personal friend called up with a problem; he was scheduled to present a lecture on hedge fund money laundering the next morning at a conference on Miami Beach, but his firm had just ordered him to fly immediately to Argentina on urgent business. Since I am known for being able to speak at length, without notes, on most major AML topics, he asked me to take the lecture, to be presented early the next morning. If you've been reading this series since its inception in 2006, you know what my answer was; yes, of course. I took the offer as an intellectual challenge to be accepted.The programme organiser was a group from New York, and the conference took place at a boutique hotel on Collins Avenue. Arriving at the venue, I noticed that I knew one of the attendees, the director of compliance at a major investment firm located in Fort Lauderdale. She was there with the company's CFO, who was a certified public accountant .

After my lecture, the compliance director spoke to me, and advised that it would be in the best interests of their firm to have me speak with the staff on money laundering issues, which were apparently not being taken seriously by some of the senior new accounts sales staff in the company. I traveled to Fort Lauderdale soon after that, presented a lecture, and spent some time with the company's owner.

The in-house presentation to company staff was well received by management, and my relationship with the company began:

  • As a result of that visit, I was engaged as a compliance consultant for certain specific enhanced due diligence projects involving large investments being made by individuals. My job was to ascertain the level of risk posed by these prospective clients, and to advise if my investigation revealed information that made them unacceptable risks as clients.
  • One day, I was urgently called to the company headquarters with a priority enhanced due diligence assignment. A major new client was interested in investing $15m with the firm. The company's outside compliance counsel, a major law firm, had passed upon the suitability of the client, but the firm's owner wisely reached out to me for a second opinion. He asked me to take a close look at the client and the transaction, as it was about to be approved and processed, and he wanted to be sure. He was puzzled by the fact that the investment was to be made through a Gibraltar corporation, though the client, who was a Russian national, was employing a financial services professional who was located in Switzerland.
  • I then undertook an enhanced due diligence investigation, and found that the Gibraltar company was owned by a Netherlands Antilles company, that was owned by the client, who had risen very quickly to a exalted position in the Russian business community. His roots, however, appeared to be in minor crime.
  • The financial adviser had an unsavory history, too. Involvement in a massive billion-dollar Russian money laundering scheme, where no Russian nationals (or Europeans) have ever been charged. I do not mention it by name, but I am sure our readers can guess which one it was.
  • The last straw was a photograph that I obtained, showing the client on the tarmac at an airport in Eastern Europe, greeting a prominent arrival, whom I later determined to be his patron and mentor. The passenger that he was greeting was one of the Russian Oligarchs, a reputed billionaire, whose source of wealth remains a mystery.
  • I brought my research to the company owner and the director of compliance at a meeting where a red-faced bank counsel admitted that he was indeed unacceptable as a client, notwithstanding the huge amount of new business his financial adviser was dangling in front of the company.
  • Based upon that success, the company asked me to put in a minimum of four hours per day, as an in-house compliance officer, handling exclusively the high-risk cases, and those requiring enhanced due diligence investigations. The owner knew about my RICO conviction, but brought me in nevertheless, due to my "unique" qualifications, and the fact that I had prevented a probable money launderer from gaining access to the firm's investments.

I was in the door; it was to be a wild ride.

Next week: Working at a firm with problems.


 



































































































 

The facts and opinions stated in this article are those of the author and not those of World-Check. World-Check does not warrant the accuracy of any facts and opinions stated in this article, does not endorse them, and accepts no responsibility for them.

Read more in this exciting series

Confessions of a Money Launderer - Part 96
Confessions of a Money Launderer - Part 95
Confessions of a Money Launderer - Part 94
Confessions of a Money Launderer - Part 93
Confessions of a Money Launderer - Part 92
Confessions of a Money Launderer - Part 91
Confessions of a Money Launderer - Part Ninety
Confessions of a Money Launderer - Part 89
Confessions of a Money Launderer - Part 88
Confessions of a Money Launderer - Part 87
Confessions of a Money Launderer - Part 86
New chapter out Tonight
Confessions of a Money Launderer - Part 85
Confessions of a Money Launderer - Part 84
Confession of a Money Launderer - Part 83
Confessions of a Money Launderer - Part 82
Confessions is on holiday until 5 January, but read earlier chapters here
Confession of a Money Launderer - Part 81
Confession of a Money Launderer - Part 80
Confession of a Money Launderer - Part 79
Confessions of a Money Launderer - Part 78
Confessions of a Money Launderer - Part 77
Confessions of a Money Launderer - Part 76
Confessions of a Money Launderer - Part 75
Confessions of a Money Launderer - Part 74
Confessions of a Money Launderer - Part 73
Confessions of a Money Launderer - Part 72
Confessions of a Money launderer - Part 71
Confessions of a Money Launderer - Part 70
Confessions of a Money Launderer - Part 69
Confessions of a Money Launderer - Part 68
Confessions of a Money Launderer - Part 67
Confessions of a Money Launderer - Part 66
Confessions of a Money Launderer - Part 65
Confessions of a Money Launderer - Part 64
Confessions of a Money Launderer - Part 63
Confessions of a Money Launderer - Part 62
Confessions of a Money Launderer - Part 61
Confessions of a Money Launderer - Part 60
Confessions of a Money Launderer - Part 59
Confessions of a Money Launderer - Part 58
Confessions of a Money Launderer - Part 57
Confessions of a Money Launderer - Part 56
Confessions of a Money Launderer - Part 55
Confessions of a Money Launderer - Part 54
Confessions of a Money Launderer - Part 53
Confessions of a Money Launderer - Part 52
Confessions of a Money Launderer - Part 51
Confessions of a Money Launderer - Part 50
Confessions of a Money Launderer - Part 49
Confessions of a Money Launderer - Part 48
Confessions of a Money Launderer - Part 47
Confessions of a Money Launderer - Part 46
Confessions of a Money Launderer - Part 45
Confessions of a Money Launderer - Part 44
Confessions of a Money Launderer - Part 43
Confessions of a Money Launderer - Part 42
Confessions of a Money Launderer - Part 41
Confessions of a Money Launderer - Part 40
Confessions of a Money Launderer - Part 39
Confessions of a Money Launderer - Part 38
Confessions of a Money Launderer - Part 37
Confessions of a Money launderer - Part 36
Confessions of a Money Launderer - Part 35
Confessions of a Money launderer - Part 34
Confessions of a Money Launderer - Part 33
Confessions of a Money launderer - Part 32
Confessions of a Money launderer - Part 31
Confessions of a Money launderer - Part 30
Confessions of a Money Launderer - Part 29
Confessions of a Money Launderer - Part 28
Confessions of a Money Launderer - Part 27
Confessions of a Money Launderer - Part 26
Confessions of a Money Launderer - Part 25
Confessions of a Money Launderer - Part 24
Confessions of a Money Launderer - Part 23
Confessions of a Money Launderer - part 22
Confessions of a Money Launderer - Part 21
Confessions of a Money Launderer - Part 20
Confessions of a Money Launderer - Part 19
Confessions of a Money Launderer - Part 18
Confessions of a Money Launderer - Part 17
Confessions of a Money Launderer - Part 16
Confessions of a Money Launderer - Part 15
Confessions of a Money Launderer - Part 14
Confessions of a Money Launderer - Part 13
Confessions of a Money Launderer - Part 12
Confessions of a Money Launderer - Part 11
Confessions of a Money Launderer - Part 10
Confessions of a Money Launderer - Part 9
Confessions of a Money Launderer - Part 8
Confessions of a Money Launderer - Part 7
Confessions of a Money Launderer - Part 6
Confessions of a Money Launderer - Part 5
Confessions of a Money Launderer - Part 4
Confessions of a Money Launderer - Part 3
Confessions of a Money Launderer - Part 2
Confessions of a Money Launderer - Part 1
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